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Privacy Policy

WHY HAVE WE PREPARED THIS POLICY?

At FULL COLOR we understand that privacy is important and are committed to ensuring that personal information is processed in accordance with applicable data protection and privacy laws. We have put together this privacy policy which you are currently reading (“Policy”) to help you understand what information we collect from users of the FULL COLOR App and the FULL COLOR website (FULL COLORUSA.com) and how we use and share this information. This Policy is part of and subject to our Terms of Use for the FULL COLOR Services. Please read it carefully. By using the FULL COLOR Services you are agreeing to be bound by this Policy in respect of the information collected about you via the FULL COLOR Services and you consent to the use and disclosure of that information as described in the Policy.

WHAT DOES THIS POLICY COVER?

Unless we tell you otherwise, the Policy applies as between FULL COLOR and any natural person who uses the FULL COLOR App or the FULL COLOR website. The Policy deals with our use of information collected by us in relation to your use of the FULL COLOR App or the FULL COLOR website.

Please be aware that some versions of our FULL COLOR App or third party apps provided for use with a particular FULL COLOR POWERED product or experience may have a different privacy policy which is unique to that App. This privacy policy will normally be located within the App itself. For Apps which have their own in-app privacy policy, the provisions of that policy will apply in place of this Privacy Policy.

WHAT DOES THIS POLICY NOT COVER?

This Policy does not apply to personal data and other information which we collect from users of Our FULL COLOR CREATOR service. Users of FULL COLOR CREATOR should refer to the specific Privacy Policy provided with that service available at https://zap.works/

equally, this Policy does not extend to any websites or services of third parties which can be accessed from the FULL COLOR Services including any links we may provide to social media sites.

WHAT MEANS WHAT?

In this Policy certain words with a Capital letter have a particular meaning. These are listed below:

“Anonymous Information”

means information that does not identify and cannot reasonably be used to identify a specific individual. When Anonymous Information is associated with Personal Data, this Anonymous Information is treated by FULL COLOR as Personal Data.

“Content”

means content made available on or via the FULL COLOR Services. This might include animation, documents, images, links, sound files, videos, text, and other stuff.

“Information”

means any or all information that you or your device send, submit or transmit to FULL COLOR via the FULL COLOR Services, including information automatically collected by us.

“IP Address”

means an Internet Protocol address, a number that is automatically assigned to your device when you use the internet and which may vary from session to session.

“Personal Data”

means any information which could be used to identify who you are, e.g. your name, email, home address, IP Address and may include other information such as identification numbers and location data.

“Third Party Content”

means Content which is owned or controlled by a person other than FULL COLOR including content which is licensed to us by a brand or an entertainment franchise; and Content which is published on our platform by users of our FULL COLOR CREATOR service.

“you”, “your”

means you, the natural person browsing the FULL COLOR Website, using the FULL COLOR App, or using other FULL COLOR Services.

“Zap”

means an augmented, virtual or mixed reality content experience.

“FULL COLOR”, “we”, “our”, “us”

means FULL COLOR Inc. is incorporated in Delaware, United States of America.

“FULL COLOR App”

means our augmented reality interactive entertainment application for smartphones and tablets entitled FULL COLOR including all versions of that application published by us which may be available for download from time to time from the App Store or Google Play Store.

“FULL COLOR Services”

means collectively the FULL COLOR App, the FULL COLOR Website, our FULL COLOR POWERED products and any other applications, products or services of FULL COLOR which you may use unless excluded in the section entitled “What Does this Policy Not Apply to?”. A reference to “FULL COLOR Services” includes any and all related databases, features, functionality, plug-ins, software and web pages and with respect to FULL COLOR POWERED products, experiences which

Where we refer to a “person” this includes individuals, companies, corporations, partnerships, limited liability partnerships, co-operatives, associations and other natural and legal persons.

In addition to the above defined terms, when we use the words “includes” or “including” we are not limiting ourselves in any way and mean “includes or including without limitation”.

IDENTITY OF THE DATA CONTROLLER

The data controller is FULL COLOR Inc, a registered corporation in Delaware United States of America. Our contact details are shown below in the section headed “How to Get in Touch”. Third parties, such as Full Color publishers, are the controllers with regard to the processing of your Personal Data in connection with your use of Third Party Content and, in that capacity, are solely responsible for compliance with applicable data protection and other legislation and regulation with regard to such processing.

YOUR RIGHTS

As a data subject, you have the following rights under the United States data protection, which this Policy and our use of Personal Data have been designed to uphold:

The right to be informed about our collection and use of Personal Data;

The right of access to the Personal Data we hold about you (see “How can you access your Personal Data”);

The right to rectification if any Personal Data we hold about you is inaccurate or incomplete (please contact us using the details in “How to Get in Touch”);

The right to be forgotten – i.e. the right to ask us to delete any Personal Data we hold about you;

The right to restrict (i.e. prevent) the processing of your Personal Data;

The right to data portability (obtaining a copy of your Personal Data to re-use with another service or organization);

The right to object to us using your Personal Data for particular purposes; and

Rights with respect to automated decision making and profiling.

You have the right to opt-out link/third-party tool is strongly recommended. Some available third-party opt-out tools include: the , the , and the .

When making a request, please be aware that we may be unable to delete Information that resides in our archives, and the requested removal of certain Information may mean we are no longer able to provide you with all or certain parts of the FULL COLOR Services.

If you have any cause for complaint about our use of your Personal Data, please contact us using the details provided in “How to Get in Touch” and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the US’s supervisory authority, the Information Commissioner’s Office.

INFORMATION THAT WE COLLECT FROM YOU

As and when you visit, browse or use FULL COLOR Services we may collect certain Information from you. Some of this Information may be Personal Data and some of the Information may be Anonymous Information. We will only use your Information in accordance with the terms of this Policy.

Collection and user registration

Some features of the FULL COLOR Services may require you either to confirm your country and age (*) and/or register before you can access those features (e.g. photo share, newsletter). You may be asked to provide certain Information about yourself. This could be one or more of the following items of Personal Data:

Your name,

Your email address,

Your post code,

Your country of residence,

Username and password.

* Age information is not stored by us.

Below is a list of some of the other Information we may collect from you, depending on how you interact with FULL COLOR:

Emails sent to FULL COLOR and messages submitted via the FULL COLOR Website

Competition entries

Responses to surveys and feedback requests

User Generated Content

Information given to us by other companies,

device information, and

information relating to your use of the FULL COLOR App.

Emails and other Information submitted to FULL COLOR

If you choose to email or write to FULL COLOR about the FULL COLOR Services, or you fill in an on-line contact or support request form available on the FULL COLOR Website, we may collect Information about you from the content of your letter, email or other message e.g. your name, your email address, and what you like or dislike about FULL COLOR. If you participate in a competition or promotion, or respond to a survey or feedback request then in addition to your entry or response we may collect your name, email and/or other contact details.

User Generated Content

Some features of the FULL COLOR Services may allow you to create, submit, post, display, transmit or share content (e.g. photos, videos, comments, messages, and other materials) on or through the FULL COLOR Services (we call this “User Generated Content”).

When you use the FULL COLOR App we will only collect and store your User General Content, if you choose to share an animated GIF from within an experience, or you upload content. We do not collect or store any photos or videos that you take within an experience, even if you choose to share that content with others.

Some of your User Generated Content may contain personal details about you or other natural persons, e.g. audio, photos or videos featuring you or your friends. We therefore advise you to be selective about what personal details you include in User Generated Content, and not to include any of the following types of personal information in any submission to any publicly available area of the FULL COLOR Services: telephone numbers, physical addresses, full name or any other information of a sensitive nature. If you upload personal details about or depicting other individuals (e.g. a photo of a friend), you must obtain their consent first.

Please be aware that even if you remove personal details that you post to the FULL COLOR Services, copies may still remain in cached and archived pages of the FULL COLOR Services or on another user’s device.

IT IS ALSO IMPORTANT TO NOTE THAT YOU AND NOT FULL COLOR ARE RESPONSIBLE FOR, AND CONTROL YOUR USER GENERATED CONTENT. IF YOUR USER GENERATED CONTENT CONTAINS ANY PERSONAL INFORMATION OF OTHERS THEN UNLESS THIS IS A PURELY PERSONAL OR HOUSEHOLD ACTIVITY YOU MAY HAVE OBLIGATIONS AS A ‘DATA CONTROLLER’ UNDER APPLICABLE DATA PROTECTION LAW THAT YOU NEED TO COMPLY WITH.

Information collected from Third Parties

We may, from time to time, employ the services of other companies to handle certain tasks relating to the FULL COLOR Services. This may include payment processing, search engine facilities, storage and serving of content, advertising and marketing, and analytics. These providers may send us Personal Data relating to you. We may also collect information about you from publicly available sources, such as via the internet and social networks, including through public or licensed APIs. If we do collect such information from Third Parties, we will only use that information in accordance with this Policy. Equally, these companies may collect Personal Data directly from you. If they do, that company and not FULL COLOR will be the data controller in respect of any information you provide to them (e.g. your credit card details) and you should check their privacy policy to find out how they will use your information.

Information About Your Device And Your Use Of The FULL COLOR APP

When you use the FULL COLOR App, our servers will automatically collect information from your mobile device, including the following:

an Installation ID (see below);

the IP Address linked to the device (we will process this once to infer coarse user location, but the IP Address is not stored by us);

the time;

the make and model of your device (including operating system version);

the version of the FULL COLOR App being used; and

information about your use of the FULL COLOR App (we call these “alytics”).

We may use this Anonymous Information to analyze and optimize your use of the FULL COLOR Services; to develop new features and functionality; or to develop new products or services which we believe may be of use to you or other users of the FULL COLOR App.

FULL COLOR APP installation ID

The Installation ID is a unique installation ID generated by the FULL COLOR App when it is first run. The ID is a random number, seeded from the system time and cannot be used to identify who you are. The ID is stored in the app’s storage directory on your device and is used to anonymously track your use of the FULL COLOR App in the following ways:

when you open the FULL COLOR App;

when you scan;

when you perform certain actions during a scan e.g. completing a game;

how long you spend interacting with a scan;

to confirm that you are allowed to use an age-restricted feature of the FULL COLOR App.

The Installation ID is not accessible to other apps or sites on your device and does not track you beyond the FULL COLOR app. We do not share the Installation ID within any third party.

Log Data – FULL COLOR websites

Our systems will automatically record and store information created by your access to and use of our websites, including specific actions performed by you within these FULL COLOR Services (collectively, “Log Data”). This may include information about your device, your IP Address, browser type, the pages that you visit, time spent on pages and other statistics. We use this information to better tailor the FULL COLOR Services to our users’ needs and to provide you with targeted communications that you are happy to receive from us. We may also link this automatically collected information to Personal Data (e.g. if you submit a CONTACT US request or register for a FULL COLOR CREATOR trial). We may also add Log Data to our customer relationship management system.

We do not use any Log Data to track you outside of the FULL COLOR Services

GPS Location Data

FULL COLOR does not currently receive or process any GPS location data provided by you or which we receive from location service providers. We may however wish to do so in the future to tailor the FULL COLOR Services offered to users in a particular geographical location. If this becomes the case, we will only process GPS location data for which you gave us your consent, including your GPS location, which were provided by you or which we receive from GPS location service providers, but only for so long as this is necessary for delivering the FULL COLOR Services and/or to the extent required as permitted by applicable law.

HOW DOES FULL COLOR USE YOUR INFORMATION?

Our use of your Personal Data will always have a lawful basis, either because it is necessary for our performance of a contract with you ( e.g. to carry out a user action you have requested), because you have consented to our use of your Personal Data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your Information for the following purposes:

to enable us to provide you with all features and functionality of the FULL COLOR Services and to enable you to consume Content;

to enable you to create and share User Generated Content;

to provide you with personalised content and promotional communications that you are happy to receive from the FULL COLOR Services;

to provide customer service in relation to your use of the FULL COLOR Services, e.g. service updates, responding to support requests;

generally to administer, support, analyze, improve and develop the FULL COLOR Services, including automatically updating the FULL COLOR App on your device and detecting, preventing, or otherwise addressing fraud, security or technical issues; and

as otherwise described in this Policy.\

When visitors come to your site, third parties (such as AdRoll) may place cookies on their browsers for targeted advertising purposes

PROFILING AND AUTOMATED DECISION MAKING

We do create and maintain user profiles relating to some visitors to our websites. These profiles are created when a visitor fills in a form on FULL COLORUSA.com or registers for a FULL COLOR CREATOR. No profiles are created for visitors who just browse the site(s). Our aim is to limit the Personal Data contained in these profiles to that required to achieve our legitimate interest of helping users get the best from our FULL COLOR CREATOR tools and better tailoring communications we send people.

We also apply some automatic decision making: we use a marketing automation tool called Intercom which decides the type of email you will receive based on who you are (e.g. a designer) and what actions you have performed within the FULL COLOR Services. This means you may receive a different email from someone else. In our view, this is the only consequence of the automation tool we use.

MARKETING COMMUNICATIONS

We may use your Information to send you notifications and information about the FULL COLOR Services and other FULL COLOR products and services we think may be of interest to you. If you have consented to receive marketing, you may opt out at a later date. If at any time you no longer wish to be contacted for this purpose, please let us know and we will remove you from our mailing list. Please note that You may not opt out of service related emails as these are necessary for the security and performance of the FULL COLOR services.

HOW AND WHERE WILL YOUR INFORMATION BE PROCESSED?

We use Amazon Web Services (“AWS”) to store and process data on our behalf in connection with the FULL COLOR Services.

We use AWS servers located around the world to cache data locally and speed up access to Content.

We may appoint other third parties to carry out certain data processing on our behalf. For example, we may appoint a third party as a payment provider, to host the FULL COLOR Services, to administer electronic mailings on our behalf, or to provide analytics services. We will continue to be the data controller in respect of any Information transferred to or shared with such third parties and shall remain responsible for the processing undertaken by them.

The following is a list of the main third parties who currently process data on our behalf in relation to the FULL COLOR Services:

Name

Processing purpose(s)

Data Storage location

Amazon Web Services (AWS)

Content hosting and serving

Primary storage location is Ireland, but content may be cached locally to improve content delivery performance.

Fresh Desk

User support requests

USA

Google

Business email and analytics services

Worldwide

HubSpot

Customer relationship management tools

USA

Intercom

Analytics Services

USA

Stripe

Payments for IA Creator and order fulfillment

Worldwide

USERS LOCATED IN THE UNTIED STATE OF AMERICA

If we transfer any of your Personal Data outside the USA (e.g. to a third party data processor located outside the USA) we shall take all steps reasonably necessary to ensure that your Personal Data is adequately protected by only using processors who comply with US data protection laws. If you use the FULL COLOR Services while you are outside the USA, your Personal Data may be transferred to countries outside the USA (including countries within the EU) to enable us to provide you with those services. As the FULL COLOR App is available for use internationally it is possible that any Personal Data contained in your User Generated Content (e.g. your picture) that you publish on our platform (e.g. by connecting content to Full Color, or sharing an animated GIF) may be automatically transferred by our servers to a device, server or other computer equipment being used in a country outside the USA where they have a different level of data protection.

By using the FULL COLOR Services you specifically give your consent to the international transfers referred to in this section.

WHEN MIGHT FULL COLOR SHARE YOUR INFORMATION WITH OTHERS?

Other than as expressly set out in this Privacy Policy or as otherwise required or permitted by law or regulatory requirement, we will not share, sell or transfer any of the Information you provide to us without your consent.

We may disclose Your INFORMATION to or share it with the following:

other users where you allow Information to be made public;

social media services you choose to share Information with;

any third party to whom disclosure is necessary to enable us to provide you with the FULL COLOR Services including our server provider(s);

other companies that we have hired to provide services on our behalf e.g. providers of analytics services and customer relationship management tools;

any third party to whom disclosure is necessary to protect the rights, property or safety of the FULL COLOR Services, its users and the public. This includes exchanging Information with other companies and organizations for fraud protection and spam prevention;

users of FULL COLOR CREATOR will get to see information about your device and your use of the FULL COLOR App, but only in de-identified and aggregated form;

any person to whom disclosure is necessary to enable us to enforce our rights under this Policy or under our Terms of Use;

our business partners, which may include advertising, brand and retail partners for the purposes of providing certain services available within the FULL COLOR services that are offered in conjunction with those partners. This Information would, for example, allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of interest to you;

to inform business partners about use of the FULL COLOR Services and products and services made available through the FULL COLOR Services, in the form of aggregated statistics or otherwise in a format that does not identify you personally;

any prospective purchaser of FULL COLOR Inc, its parent company, or the FULL COLOR Services or any part thereof (see below);

any subsidiary or holding company of FULL COLOR Inc or any subsidiary of any such holding company for use by them in accordance with this Privacy Policy; and

other outside parties (e.g. judicial or regulatory authorities) to comply with the law and legal obligations.

CONTROLLING THE USE OF YOUR INFORMATION

By submitting your Information, you consent to the use of that Information as set out in this Policy. You may withdraw your consent for FULL COLOR to process your Personal Data for direct marketing purposes at any time by notifying us in writing (an email will suffice).

You are always free to opt-out from the future collection of your Personal Data by FULL COLOR in accordance with this Policy by uninstalling the FULL COLOR App from each of your devices and discontinuing use of the FULL COLOR Services.

CHANGES OF BUSINESS OWNERSHIP AND CONTROL

FULL COLOR may from time to time expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of FULL COLOR or the FULL COLOR Services. Information provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part as one of the transferred assets. The new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Information for the purposes for which it was originally supplied to FULL COLOR.

We also reserve the right to disclose de-identified user data to the prospective buyer of such business or assets.

LINKS TO NON-FULL COLOR SERVICES

The FULL COLOR Services may contain links to websites, microsites and other on-line services that are operated by third parties (i.e. businesses other than FULL COLOR) (collectively, “Third Party Services”). FULL COLOR does not control these Third Party Services and is in no way responsible for their content, or information collection practices. This Policy does not apply to your use of any Third Party Services.

Please consult the terms and conditions and privacy policy of any Third Party Service you choose to access to find out how they will collect, use and share your personal information and to establish whether and for what purpose they use cookies and similar technologies. Some Third Party Content contained on or accessible via the FULL COLOR Services may operate as links to that third party’s website(s) and as such any information they collect by virtue of your clicking on that link will be collected and used in accordance with the privacy policy of that third party.

HOW DO WE KEEP YOUR PERSONAL DATA SECURE?

Data security is of great importance to FULL COLOR. We have put in place commercially reasonable physical, electronic and managerial security measures to protect your Personal Data from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage.

Specifically, we use the following measures:

The Information you send FULL COLOR is protected by SSL/TLS end-to-end encryption when transmitted from your servers to our servers.

Information stored on our servers is protected by encryption, key authentication and by firewalls. Your Information will only be accessed by authorized employees. These employees are obliged to preserve the confidentiality of all information that comes to their attention unless disclosure is compulsory by law or necessary for the fulfillment of their duties.

Even though FULL COLOR has taken the above security measures given the nature of on-line communications we cannot 100% ensure the security of your Information or guarantee that your Personal Data will not be accessed, disclosed, altered or destroyed by an unauthorized person who is determined to circumvent our security measures.

HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

We will retain your Personal Data for the duration of your use of the FULL COLOR Services and for a reasonable period thereafter for backup, archival and/or audit purposes or for as long as the law otherwise requires or permits. Where you have chosen to upload User Generated Content to a Full Color Creator of a third party we will need to continue to store your content on our servers for so long as the third party wishes to have access to your content in accordance with any legal contract you or FULL COLOR may have entered into with that party.

User profiles created by our marketing automation tool (Intercom) are automatically deleted, if a user is inactive for 90 days.

HOW CAN YOU ACCESS YOUR PERSONAL DATA?

You have the right to ask for a copy of any of your Personal Data held by us (where such data is actually held by us and we can identify who you are). We will normally provide copies in response to your request free of charge. We do, however, reserve the right to charge a reasonable fee for requests which are manifestly unfounded or excessive, particularly if it is repetitive and for further copies of the same information.

We will ask you to provide reasonable proof of your identity before we disclose any Information to you.

This section of the Policy applies if any FULL COLOR Services are accessed from within the USA or any other country which requires parental consent to be obtained before any collection of personal information from a child under the age of 13.

FULL COLOR does not knowingly collect or solicit personal information from children under the age of 13. The FULL COLOR Services and their Content are not intentionally directed at children under the age of 13 and we do not target children under 13 as our primary audience. In the event we learn that we have inadvertently collected personal information from a child under the age of 13, and that child lives in a country which does not permit such collection without prior parental consent, we will delete that information as quickly as possible.

If a parent or legal guardian becomes aware that their child under the age of 13 has provided us with personal information without prior parental consent, please contact us at the address below and we will delete such information from our files.

So we can comply with international privacy laws, we may use age screens for certain features of the FULL COLOR App. We do not store any individual’s date of birth.

USE OF THE FULL COLOR APP BY YOUNG CHILDREN

Parents and guardians should also be aware that the FULL COLOR Services are a general audience service and provide a wide variety of content and experiences some of which may be of a nature unsuitable for young children. Our FULL COLOR CREATOR service allows users to publish their content by linking it to a printed image (e.g. posters, business cards, flyers). FULL COLOR has no control over this and FULL COLOR CREATOR is an open system which means that content published via FULL COLOR CREATOR can potentially be accessed and viewed by anyone who uses the FULL COLOR App to scan an image. If you have any concerns, you may wish to monitor your child’s use of the FULL COLOR App and FULL COLOR recommends that you do not allow your child to use the FULL COLOR App with certain materials displaying Full Color call to action.

COOKIES AND ANALYTICS

Please see our separate page on cookies for information on how FULL COLOR uses cookies, analytics and similar technologies in connection with the FULL COLOR website: https://www.FULL COLOR.com/cookie-policy.

Use of Intercom Services: We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as your email address and sign-up date) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website(s) or use our product(s). Intercom analyzes your use of our website(s) and/or product(s) and tracks our relationship so that we can improve our service to you. We may also use Intercom as a medium for communications, either through email, or through messages within our product(s).

Our use of Intercom causes a unique cookie ID called intercom-* to be associated with each person who accesses our website(s), which cookie ID enables Intercom to provide us with the analytics services. The duration of this cookie id is determined by Intercom.

If you would like to opt out of having this information collected by or submitted to Intercom, please contact us.

CHANGES TO OUR PRIVACY POLICY

The FULL COLOR Services, our collection and use of Personal Data and the laws and regulations which apply will change over time. We reserve the right to make changes to this Policy. If we do, the changes to the Policy will be posted to the FULL COLOR Website or made available within the FULL COLOR App – we will change the “Last Updated” date show below. You are deemed to have accepted the wording of the amended Policy on your first use of any FULL COLOR Services following the changes. We encourage you to visit this page from time to time for the latest on our information collection practices.

CONTACTING US

If you have any questions about the FULL COLOR Services or this Privacy Policy, please contact us by email or by post using the details below. Please ensure that your query is clear, particularly if it is a request for information about the Personal Data we hold about you.